ML20215E188
| ML20215E188 | |
| Person / Time | |
|---|---|
| Issue date: | 09/30/1986 |
| From: | NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | |
| Shared Package | |
| ML20215E189 | List: |
| References | |
| TASK-CE-402-4, TASK-RE REGGD-03.050, REGGD-3.050, NUDOCS 8610150100 | |
| Download: ML20215E188 (19) | |
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+ paas h September 1986
[ g U.S. NUCLEAR REGULATORY COMMISSION Division 3
- r. ! 0FFICE OF NUCLEAR REGULATORY RESEARCH Task CE 402-4
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) **,,,,,*#, DRAFT REGULATORY GUIDE AND VALUE/ IMPACT STATEMENT v'
Contact:
W. R. Pearson (301)443-7682 PROPOSED REVISION 1 TO REGULATORY GUIDE 3.50 GUIDANCE ON PREPARING A LICENSE APPLICATION TO STORE SPENT FUEL AND HIGH-LEVEL RADI0 ACTIVE WASTE l, INTRODUCTION Subpart B, " License Application, Form, and Contents," of-10 CFR Part 72,
" Licensing Requirements for the Independent Storage of Spent Nuclear Fuel and High-Level Radioactive Waste,"** specifies the information to be covered in an application for a license to store spent fuel'in an independent spent fuel storage installation (ISFSI) or to store spent. fuel and high-level radioactive waste in a monitored retrievable storage (MRS) installation. However, Part 72 does not specify the format to be followed in the license application. This regulatory guide suggests a format acceptable to the NRC staff for submitting
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the information specified in Part 72 for a license application to store spent fuel in an ISFSI or to store spent, fuel and high-level radioactive waste in an MRS.
Other regulations applicable to licensing the storage or spent fuel in an ISFSI or spent fuel ~and high-level radioactive waste in an MRS are in the l following parts of Title 10, " Energy," of the Code of Federal Regulations:
Rules of Practice for Domestic Licensing Proceedings 2 -
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Interpretations 8610150100 860930 PDR REGGD 03.000 R PDR
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- Lines indicate substantive changes from the previous issue.
- All references to 10 CFR Part 72 in this proposed revision to this regulatory guide refer to the proposed version of 10 CFR Part 72 that was published for comment in the Federal Register on May 27, 1986 (51 FR 19106).
This regulatory guide and the associated value/ impact statement are being issued in draft for's to involve the public in the early stages of the development of a regulatory position in this area. They have not rece'ved complete staff review and do (y not represent an official NRC staff position.
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) Pubite comments are being solicited on both drafts, the guide (including any implementatiore schedule) and the value/ impact statement. Comments on the value/ impact statement should be accompanied by supporting data. Written comments may be sub-mitted to the Rules and Procedures Branch, ORR. ADM, U.S. Nuclear Regulatory Commission, Washington, DC 20555. Comments I may also be delivered to Room 4000, Maryland National Bank Building, 7735 Old Georgetown Road, Bethesda, Maryland from 8:15 a.m. to 4:00 p.m. Copies of comments received may be examined at the NRC Public Doctment Room,1717 H 5treet NW. ,
Washington, OC. Comments will be most helpful if received by December 1, 1986.
Requests for single cooles of draft guides (which may be reproduced) or for placement on an automatic distribution IIst for single copies of future draft guides in specific divisions should be made in writing to the U.S. Nuclear Regulatory Commission, Washington, DC 20555. Attention: Director, Division of Technical Information and Doctment Control.
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Public Records 11 -
Criteria and Procedures for Determining Eligibility for Access to or Control over Special Nuclear Material 19 -
Notices, Instructions and Reports to Workers; Inspections 20 -
Standards for Protection Against Radiation 21 -
Reporting of Defects and Noncompliance 25 -
Access Authorization for Licensee Personnel 51 -
Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions 73 -
Physical Protection of Plants and Materials 75 -
Safeguards on Nuclear Material--Implementation of US/IAEA Agreement 95 -
Security Facility Approval and Safeguarding of National Security Information and Restricted Data 150 -
Exemptions and Continued Regulatory Authority in Agreement States and in Offshore Waters Under Section 274 170 -
Fees for Facilities and Materials Licenses and Other Regulatory Services Under the Atomic Energy Act of 1954, as Amended.
Part 72 provides for a single licensing procedure. The smooth functioning of this one-step licensing procedure requires that the license application be essentially complete in its initial submittal. A license under this part will be issued before the start of construction of any physical facilities at the storage site involved. Under this procedure, the final design details of those l ISFSI or MRS components, systems, and structures that are important to safety must be available for review and evaluation. Part 72 also requires that a site 1 I
evaluation be provided to ensure that the natural characteristics of the site and its environs are sufficiently known and have been factored into the engi-neering design of the installation. The document in which this information is presented is a safety analysis report (SAR).
Although an applicant may plan to contract with another organization for the design, construction, and possibly the operation of the proposed ISFSI or l MRS, a licensee under Part 72 cannot Jelegate to a contractor the responsibility for meeting applicable regulatory requirements. This means that the applicant must make a commitment that, as the licensee, it will have an adequate staff 2
to ensure that regulatory requirements are met at each stage of the proposed project. If the applicant plans to contract with another organization for the operation of the proposed ISFSI or MRS, the contractual arrangements must be l described in the license application. Any subsequent changes in such contrac-tual arrangements may require an amendment to the application.
This regulatory guide represents a standard format that is acceptable to the NRC staff for the license application. Conformance with this guide, how-ever, is not mandatory. License applications with different formats will be acceptable to the NRC staff if they provide an adequate basis for the findings required for the issuance of a license. However, because it may be more difficult to locate needed information, the staff review time may be longer, and there is a greater likelihood that the staff may regard the license appli-cation as incomplete.
As experience is gained in the licensing of spent fuel and high-level radioactive waste storage, the Commission's requirements for information needed in its review of applications for licenses to store radioactive material in an ISFSI or MRS may change. Revisions of the Commission's needs for information
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Prospective applicants are encouraged to meet with representatives of the Division of Fuel Cycle and Material Safety of the Office of Nuclear Material Safety and Safeguards during the development of a license application to resolve any problems that may arise. An early resolution of potential problems is beneficial to all concerned with the licensing process.
Contents of the License Application the license application is the basic document that must address each of the requirements of Part 72 and must be complete in itself. However, the following subjects should be covered in separate documents that are identified as enclosures to the license application, and the contents of each should be briefly summarized in the license application:
O 1. Safety Analysis Report 3
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- 2. Decommissioning Plan
- 4. Environmental Report
- 5. Quality Assurance Program
- 6. Physical Security Plan
- 8. Personnel Training Program
- 9. Proposed License Conditions, including Technical Specifications
- 10. Design for Physical Security l
- 11. Guard Training Plan Format and Style The applicant should strive for clear, concise presentation of the informa-tion provided in the application.
Abbreviations should be consistent throughout the license application and its enclosures. Any abbreviations, symbols, or special terms unique to the proposed activity or not in general use should be defined when they first appear A title page identifying key individuals responsible for the preparation of the license application and the oath required under paragraph 72.11(b) should be included. A table of contents should also be included.
Physical Specifications
- 1. Paper size: 8 x 11 inches
- 2. Paper stock and ink. Suitable quality in substance, paper color, and ink density for handling and reproduction by microfilming or image-copying equipment.
- 3. Paper margins. A margin of no less than 1 inch should be maintained on the top, bottom, and binding side of all pages.
- 4. Printina
- a. Composition: Text should be single or 1% spaced.
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equipment.
- c. Reproduction: Either mechanical or photographic. Text should be printed on both sides of the paper with the image printed head to head.
- 5. Binding. Pages should be punched for a standard 3-hole loose-leaf binder.
- 6. Chapter and page numbering. Each requirement of the regulation addressed should be shown as a separate chapter with the same number as the chapter given in this guide, e.g., Chapter 7, " Operator Training." Pages should be numbered sequentially in each chapter, e.g., 7-1, 7-2, etc. Do not number the entire document sequentially.
Procedures for Updating or Revising Pages All pages submitted to update, revise, or add to the license application should show the date of change and a change or amendment number. The changed I
or revised portion of each page should be highlighted by a " change indicator" mark consisting of a bold vertical line drawn in the margin opposite the binding side.
Referenced Materials Caution should be used in references to information previously filed with the AEC or NRC. Such references must be pertinent to the subject discussed, must contain current information, and must be readily obtainable or extractable from the referenced documents. It may be more efficient in some cases to repeat in a license application previously furnished information.
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- 1. GENERAL AND FINANCIAL INFORMATION The license application should address the requirements of 6 72.14 of 10 CFR Part 72 regarding details on the identity of an applicant. If the applicant is other than the owner or planned operator of the proposed ISFSI or MRS, details of the working and contractual arrangements between all parties involved should be set forth. Any information on such matters considered as proprietary information by the applicant should be identified and submitted under separate cover. The procedures in paragraph 2.790(b) of 10 CFR Part 2 should be followed for such information.
l If the proposed ISFSI or MRS is to be built on the site of another licensed activity or facility such as a nuclear power plant, details of the working arrangements and responsibilitit.s of the licensees involved should be stated.
Similarly, if unlicensed activities are carried out at the proposed site, any lpotentialinteractionsbetweentheproposedISFSIorMRSandtheseothersite activities should be explained.
Paragraph 72.14(e) specifically addresses the required financial infor-mation that must be submitted with the application. If the applicant is a corporation organized for the specific purpose of owning and operating the pro-posed ISFil, details of its organizational structure, including the respon-sibilities of its members to meet the financial requirements of the proposed ISFSI throughout its proposed operating life and ultimate decommissioning, must be stated. This requirement is applicable even if the proposed ISFSI is to be owned and operated by a consortium of utilities.
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N 2. TECHNICAL QUALIFICATIONS Section 72.17 and paragraph 72.31(a)(4) require a finding by the staff that the applicant is qualified by training and experience to construct and operate an ISFSI or MRS.
Although spent fuel storage in an ISFSI or spent fuel and high-level radioactive waste storage in an MRS is generally considered a relatively low-risk operation compared to some other types of nuclear activities, the design, construction, and operation of an ISFSI or MRS require certain skills and an l understanding of the requirements involved to ensure that the objective of a relatively low-risk operation is achieved in practice. The license application should contain a commitment that the applicant will staff the project with an adequate cadre of personnel possessing the required skills throughout all phases of the project. This element of the license application is in addition to the discussion of the conduct of operations covered in Chapter 9 of the SAR.
The licensee is responsible for the execution of the proposed project as described in the license application. This means that, even though much of the actual work involved during the site selection, design, procurement, con-struction, and even the operating phases of the project may be performed by a contractor, the licensee must have a staff that is knowledgeable in all aspects of the project. If such a staff does not actually exist, the applicant should describe the staffing plans in sufficient detail to support the finding required by paragraph 72.31(a)(4).
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- 3. TECHNICAL INFORMATION: SAFETY ANALYSIS REPORT As required by S 72.15, the technical information is presented in the SAR, l which should be submitted as an enclosure to the license application. A summary statement identifying the type of installation proposed (e.g. , a water-basin ISFSI, a storage-cask MRS), its design capacity, any unique features incorporated in its design, and its mode of operation is adequate for the license applica-tion document.
The SAR required for an ISFSI or MRS differs from the SARs for some other nuclear facilities in that the initial SAR is expected to be complete and com-parable in scope and detail to the final SAR for facilities licensed under 10 CFR Part 50. Section 72.15 identifies the minimum information that is required to be included in the SAR. Although S 72.50 provides for the subse-quent updating of the SAR, such changes during the design and construction phases of the project are expected to be of minor importance. Any of these changes deemed significant by the NRC staff may cause delay in the granting of the final clearance to receive spent fuel or high-level radioactive waste.
Guidance on the preparation of the SAR for an ISFSI of the conventional water-basin type is contained in Regulatory Guide 3.44, " Standard Format and Content for the Safety Analysis Report for an Independent Spent Fuel Storage Installation (Water-Basin Type)." For the dry storage ISFSI, which is not collocated at another nuclear facility site or for a dry storage MRS, guidance on the preparation of the SAR is contained in proposed Revision 1 to Regulatory Guide 3.48, " Standard Format and Content for the Safety Analysis Report for an Independent Spent Fuel Storage Installation or a Monitored Retrievable Storage Installation (Dry Storage)." Guidance for preparing the SAR for the use of dry storage casks at the site of another nuclear facility is contained in Draft Regulatory Guide CE 301-4, " Standard Format and Content for the Safety Analysis Report for Onsite Storage of Spent Fuel Storage Casks."
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O i 4. CONFORMITY TO GENERAL DESIGN CRITERIA V
Subpart F of 10 CFR Part 72 contains the general design criteria for an ISFSI or MRS. The subject of conformity to the general design criteria is l covered in detail in the SAR. It is sufficient that the license application contain a summary discussion of each criterion and reference where more detailed information on a specific subject can be found in the SAR.
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- 5. OPERATING PROCEDURES: ADMINISTRATIVE AND MANAGEMENT CONTROLS Paragraph 72.31(a)(S) requires a finding by the staff that the applicant's proposed operating procedures to protect health and to minimize danger to life or property are adequate. Essential to these operating procedures are the applicant's proposed administrative and management controls. Guidance on this subject is available in ANSI N299-1976, " Administrative and Managerial Control for the Operation of Nuclear Fuel Reprocessing Plants."* Although ANSI N299-1976 is designed for the much more complex operating requirements of a fuel repro-cessing plant, the basic principles set forth for administrative and managerial controls are considered applicable to the operation of an ISFSI or MRS. Para-graph 72.15(h) identifies the information that is to be included in the SAR.
If the proposed ISFSI or MRS is to be operated by the owner, a relatively brief explanation of how ANSI N299-1976 will be followed may be adequate. How-l ever, if the proposed ISFSI or MRS is to be operated by a contractor, consider-able detail may be required on the working arrangements between the parties involved. Particular attention should be placed on the description of the administration of the Independent Review and Audit Program that is identified in ANSI N299-1976.
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" Copies may be obtained from the American National Standards Institute, Inc., t 1430 Broadway, New York, NY 10018. I 10 l
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- 6. QUALITY ASSURANCE PROGRAM The quality assurance (QA) program required by Subpart G of Part 72 must be l submitted as an enclosure to the application and is briefly described in Chapter 11 of the SAR. It is sufficient that the license application contain a commit-ment that the QA program described is (or will be) understood by all involved in its execution and that the program will be implemented, as applicable, for all phases of the project, including any activities important to safety that have been carried out prior to submittal of the license application.
This program should cover the engineering aspects of the site investiga-tion, facility design, procurement, shop fabrication, onsite construction, preoperational testing, conduct of operations, and ultimate decommissioning.
The emphasis of this program should be on those activities and items that are identified as being important to safety. The planned QA effort should be com-mensurate with the importance to safety of the identified activities and items.
A QA program that has been accepted by NRC may be applied to the structures, systems, and components of the spent fuel storage system. The applicant should state the intent to apply this QA, the date on which the QA program was submitted to the NRC, the docket number, and the date of NRC acceptance.
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- 7. OPERATOR TRAINING l Subpart I, " Training and Certification of Personnel," of 10 CFR Part 72 requires that a training program be established and that the personnel train-ing program document be included as an enclosure to the license application.
A brief summary of the program should be included in the application. Appli-cants who have a training program in effect may modify this program to cover spent fuel storage operations. A description of the proposed changes should be provided.
ISFSI and MRS operators are not required to be licensed. However, they must have received sufficient training to successfully complete an established training program. Appropriate documentation of training activities and certi-fications of proficiency should be included in the ISFSI or MRS records.
In addition to the specific operating requirements of the planned facil-ity, the training program should also cover the nuclear engineering principles involved in the safe handling and storage of spent fuel and/or high-level radio-active waste and the regulations, regulatory guides, and national standards applicable to ISFSI and MRS operations. Guidance on the content of the required training program is available from the Advanced Fuel and Spent Fuel Licensing Branch, Division of Fuel Cycle and Material Safety, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, Washington, DC 20555.
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- 8. INVENTORY AND RECORDS REQUIREMENTS v
A description of the inventory and records system for the stored fuel and high-level radioactive waste should be included in the license application.
Section 72.51 identifies the inventory and record requirements for radioactive material stored at an ISFSI or MRS. The records on the identity of each fuel assembly or high-level radioactive waste container should be complete. As a minimum, these records should cover:
- 1. For Spent Fuel
- a. Fuel manufacturer,
- b. Date of manufacture,
- c. Reactor exposure history,
- d. Burnup,
- e. Isotope and curie content,
- f. Inventory control number, and S g. Pertinent data on discharge and storage at the reactor, transfer to the ISFSI or MRS, end storage at the ISFSI or MRS.
- 2. For High-Level Radioactive Waste
- a. Origin of waste,
- b. Isotope and curie content,
- c. Waste form,
- d. Thermal output,
- e. Inventory control number, and
If storage of consolidated fuel rods is being considered, special requirements concernirg inventory and recordkeeping for stored fuel pins should be described.
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- 9. PHYSICAL PROTECTION Subpart H, " Physical Protection," of 10 CFR Part 72 requires that a physical security plan (S 72.201), a design for physical protection (S 72.202),
and a safeguards contingency plan (S 72.203) be submitted. Since the details of the provisions for physical protection are withheld from public disclosure, this subject should be covered in separate reports. The license application should contain only a reference to the identity of the reports and when they were submitted.
Interim guidance regarding the proposed design for physical security and the format and content of the physical security plan can be obtained from the Director, Division of Safeguards, Office of Nuclear Material Safety and Safe-guards, U.S. Nuclear Regulatory Commission, Washington, DC 20555.
Guidance for the safeguards contingency plan is contained in Regulatory Guide 5.55, " Standard Format and Content of Safeguards Contingency Plans for Fuel Cycle Facilities."
If the applicant has a physical security plan and a safeguards contingency plan that have been approved by NRC, modifications may be made to cover spent fuel storage operations. A description of, and a schedule for, changes related to the spent fuel storage installation should be provided.
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l D 10. DECOMMISSIONING PLAN w
Section 72.18 requires the submittal of a decommissioning plan as part of the license application. A brief description of the decommissioning plan is
' included in Section 9.6 of the SAR. The license application need contain only a brief summary statement, enough to identify what will be involved and to provide a basis sufficient for the estimated costs of decommissioning.
However, the financial provisions for carrying out the decommissioning plan at the end of useful life of a proposed ISFSI are not necessarily addressed in the SAR and should be covered in either the license application or the decommis-sioning plan.
Applicants who have previously submitted decommissioning plans to the NRC may modify these plans to cover the spent fuel storage installation. A descrip-tion of these revisions should be submitted.
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- 11. EMERGENCY PLAN The applicant should submit a plan for coping with emergencies as a separate document. Section 72.19 of the proposed regulation sets forth infor-mation that should be included in emergency plans.
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- 12. ENVIRONMENTAL REPORT
\j Section 72.20 requires that an environmental report be provided as part of the license application. Guidance on the format and content of an environ-mental report for an ISFSI may be found in Subpart A of 10 CFR Part 51,
" Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions."
In the interest of keeping the size of this report within reasonable bounds and its structure and language keyed to the general public, it is recom-mended that a prospective applicant confer with the NRC staff to obtain defini-tive guidance on the scope and content of this report.
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- 13. PROPOSED LICENSE CONDITIONS License conditions proposed by an applicant constitute a commitment by the applicant to take the actions specified therein. Because a license issued pursuant to Part 72 is issued prior to the commencement of construction, license lconditionscovertheentireproposedlifeoftheISFSIorMRS,fromsiteselec-tion through the subsequent phases of design, construction, operation, and ulti-mate decommissioning.
License conditions can be considered in two broad categories: (1) admin-istrative and management organization and controls and (2) technical specifica-tions. Those addressing administrative and management subjects should be covered in the license application; those addressing technical subjects can be covered very briefly in the license application with appropriate references to Chapter 10 of the SAR. Care should be taken to ensure that such references are clear and explicit.
Proposed license conditions should address such subjects as:
- 1. Administrative and management organization; procedures and controls, including review and approval activities; and auditing and reporting require-ments. In particular, the subject of interfaces between the licensee and its contractors should be covered.
- 2. Verification of design features that are important to safety. Those quality assurance activities that confirm that design and construction are being carried out in accordance with plans, e.g., inspection hold points, should be covered. In particular, identify who is responsible to perform this verification.
- 3. Test procedures. Such subjects as conditions applicable to site eval-uation, component testing during design and construction, preoperational test-ing prior to startup, and conditions applicable to tests that may be desirable after the commencement of operations should be covered.
- 4. Functional and operating limits of monitoring instruments and limiting control settings. )
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- 5. Limiting conditions of operation. The functional capabilities or per-formance levels of equipment and systems that are important to safety should be addressed. The subject includes setpoint limits on monitoring instruments and any controls that may need to be imposed on personnel access to any part of the installation.
- 6. Surveillance requirements. Such items as the periodic inspection of cranes and storage structures and, for water pools, water purity and evidence l
of corrosion should be covered.
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